Kim v. State
The Sixth DCA held that a trial court need not cite specific statutory or ordinance authority for costs imposed at sentencing so long as the costs are identifiable by name (or abbreviated name) in the sentencing minutes, aligning with the Fourth and Fifth Districts and certifying conflict with the First and Second Districts' decisions in Williams and R.T.D. The court struck two costs ('State Ed TF' and 'LEEF-County') because their basis could not be determined from the record, remanding for the trial court to either identify their statutory basis or, if discretionary, hold a hearing affording the defendant notice and an opportunity to contest them.
Key facts
- Kim was sentenced in trial court, which imposed various costs at sentencing, including two costs identified as 'State Ed TF' and 'LEEF-County' whose statutory or ordinance basis could not be determined from the sentencing record.
- Kim appealed, challenging whether the trial court was required to cite specific statutory authority for each cost imposed and whether certain costs were properly identifiable.
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Why it matters
This opinion resolves a recurring issue in cost-and-fee appeals by clarifying that itemized sentencing minutes identifying costs by name (even abbreviated) satisfy due process without requiring specific statutory… — full analysis with a trial
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